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Reinsurance Tax Court

Downs Rachlin Martin PLLC

Captive Insurance Update | Spring Edition | 2019: A summary of state and federal developments in the captive insurance industry

There were no significant changes in Vermont’s leadership team during the last election cycle. Governor Phil Scott, a Republican, was re-elected in November 2018 for another two-year term. Michael Pieciak, the Commissioner of...more

Carlton Fields

Tax Court Rejects Captive Insurance Company Status Under 501(c)(15)

Carlton Fields on

Petitioner, a captive insurer domiciled in Anguilla, applied to be a tax-exempt small insurance company under IRC section 501(c)(15), and filed returns on this basis, making an election under IRC section 953(d)....more

Carlton Fields

Court Upholds Attorney-Client Privilege Despite Advice Of Counsel Defense In Tax Case Involving Reinsurance Transaction

Carlton Fields on

This case involves a tax dispute centering on whether certain “purported” insurance and reinsurance transactions “lacked economic substance.” Following an in camera review of communications identified in Respondents’...more

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